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Representations on Deposit Joint Local Development Plan - POLICY TWR3

Representation ID: 1052

OBJECT Bodafon Caravan Park (Mr Robert Roberts)

Summary:

PolicyTWR3
Explanation 7.3.60
Considers there is a need for further provision of new static caravans and chalets to meet consumer demands.
Explanation 7.3.63
considers there is scope for minor static and chalet park extensions as part of a general improvement plan in coastal areas"
Explanation 7.3.64 and 7.3.65
Considers that there is no incentive to improve sites if numbers cannot be increased
Explanation 7.3.46
Considers that a policy of no extension to existing static parks in AONB contradicts the with the Council's identification of tourism as a key priority

Representation ID: 792

OBJECT Caravan Club represented by Savills (Duncan Parr)

Summary:

In summary the policies relating to tourist accommodating are considered to be overly restrictive and lacking in clarity on the type of development which is acceptable on existing touring caravan sites. The policy should be amended to ensure that the plan does not effect the ability of local tourist businesses from adapting to the changing needs of the visitor economy and does not impact on the future economic viability of these businesses which support local economies, employments and communities.

Representation ID: 790

OBJECT Caravan Club represented by Savills (Duncan Parr)

Summary:

In summary Policy TWR3 is overly restrictive and lack clarity on the type of development which is acceptable on existing touring caravan sites. The policy should be amended to ensure that the plan does not effect the ability of local tourist businesses from adapting to the changing needs of the visitor economy and does not impact on the future economic viability of these businesses which support local economies, employments and communities.

Representation ID: 787

OBJECT Campaign for the Protection of Rural Wales (Mr Noel Davey)

Summary:

We agree with the continued moratorium on new static sites in AONBs and SLAs, but we are concerned about its relaxation elsewhere. We suggest it is maintained in otherwise unprotected buffer areas of the AONBs and within 2 km of the coast where the greatest pressures have been felt, and that only very small new sites are permitted elsewhere. We agree with continuation of a guideline limit of 10% on expansions of existing sites in all areas in return for genuine environmental improvements, but look for strengthening of effective landscaping plans, colouring standards, monitoring and enforcement.

Representation ID: 782

SUPPORT Cydbwyllgor Ymgynghorol AHNE (Cynghorydd Gruffydd Williams)

Summary:

This policy is supported as it is proposed to refuse new sites and extensions within the AONB and the SLA.

We believe that priority should be given to monitoring compliance with planning permissions, planning conditions, landscaping conditions and conditions on occupancy.

Representation ID: 757

SUPPORT Bourne Leisure Ltd represented by Nathaniel Lichfield & Partners (Mr Arwel Evans)

Summary:

Bourne Leisure does not object to point 3 and 4 in policy TWR3 as currently drafted would allow the sensitive redevelopment of caravan parks which is key to maintaining the tourism offer in the plan area which in turn has a significant positive impact on the local economy.

However, Bourne Leisure considers that it would be beneficial for the wording of this policy to be amended to embody a more positive and flexible approach whereby the constant state of change in tourism facilities is acknowledged, with redevelopment and site rationalisation to meet the needs of the dynamic tourism market.

Representation ID: 740

OBJECT Haulfryn Group Ltd represented by Lambe Planning & Design Ltd (Mr Jeremy Lambe)

Summary:

Policy TWR3 does not allow for a minor increase in pitches within the AONB compared to the existing UDP Policy (D17). To assist with funding the upgrading a site, a minor increase in the number of static holiday caravans/chalets is required.

Delete reference in point 3 of TWR3 which states "the improvements does not increase the number of static or chalet units in the site" and utilize the same wording as point 4 of TWR3 which states "a minor increase in the number of units on site will be permitted providing all of the following criteria can be met".

Representation ID: 739

OBJECT Haulfryn Group Ltd represented by Lambe Planning & Design Ltd (Mr Jeremy Lambe)

Summary:

Where holiday Caravan Parks are located within the Coastal Change Management a minor increase in the number of pitches, as part of a proposal that relocates pitches away from the shoreline affected by rising sea levels.

Holiday Park operations contribute significantly to sustainable local communities by providing a market for local goods and services, as well as providing much needed local employment.

A minor increase is necessary to fund the proposal to relocate pitches away from more vulnerable areas to avoid potential loss and fund the investment required to relocate pitches.

Representation ID: 520

OBJECT Lambe Planning & Design Ltd (Mr Jeremy Lambe)

Summary:

Where Holiday Caravan Parks are located within the Coastal Change Management Zone and within the AONB I Special Landscape Area, then a specific section should be included within Policy TWR3 that allows a minor increase to the number of pitches, as part of a proposal that relocates pitches away from the shoreline affected by rising sea levels. A minor increase is necessary to fund the proposal to relocate pitches away from more vulnerable areas to less vulnerable areas -a "rollback" position.

Changes to Plan
Policy TWR3 Para 3 point v
Add wording at the end of point v after....occupiers of caravans and chalets. "A minor increase in the number of units on site will be allowed as part of a scheme to relocate pitches away from more vulnerable areas to less vulnerable areas".

Representation ID: 519

OBJECT Lambe Planning & Design Ltd (Mr Jeremy Lambe)

Summary:

The proposed Policy TWR3 does not allow any minor increase in units within the AONB when considering proposals to improve sites.
Minor increase in the number of units is required to assist with funding of upgrading. Upgrading requires significant investment. Policy D17 of Gwynedd UDP gives an incentive to upgrade.
Minor increase in number of pitches should be allowed to assist in funding relocation of sites within Coastal Change Management Zone.

Delete the reference in point 3 of Policy TWR3 sub paragraph iii -which states "the improvements does not increase the number of static caravan or chalet units on the site and utilise the same wording as Point 4 of Policy TWR3 sub paragraph iii which states "a minor increase in the number of units on site will be permitted providing all of the following criteria can be met".

Representation ID: 517

OBJECT John Parry

Summary:

Explanation 7.3.60
Considers there is a need for further provision of new static caravans and
chalets to meet consumer demands.
Explanation 7.3.63
considers there is scope for minor static and chalet park extensions as part of a general improvement plan in coastal areas"
Explanation 7.3.64 and 7.3.65
Considers that there is no incentive to improve sites if numbers cannot be increased
Explanation 7.3.46
Considers that a policy of no extension to existing static parks in AONB contradicts the with the Council's identification of tourism as a key priority

Representation ID: 516

OBJECT Bodafon Caravan Park (Mr Robert Roberts)

Summary:

POLICY TWR3 3 does not allow any increase in numbers of units. Therefore, no incentive to Park Owners to make improvements

Changes to Plan
Add:
3(iii) a very minor increase in the number of units on site.
Explanations:
Minor is defined in para 7.3.66 as "should be no greater than a 10% increase on the number at the time of the original application".
the definition of minor should be amended to "should be no greater than a 15% increase etc
Definition of "very minor"
And "Very minor in relation to site area is not defined except in relation to an increase in the number of units and should be no greater than a 10% increase on the number at the time of the original application"

Representation ID: 515

OBJECT Bodafon Caravan Park (Mr Robert Roberts)

Summary:

Number 1
This paragraph relates to proposals for the development of new Parks and refers to "permanent alternative camping accommodation".
There is no definition of "permanent alternative camping accommodation" in the explanation 7.3.60 to 7.3.66 that follows Policy statement TWR3
Does it mean touring caravans , tents or camping, trailer tents, motor homes, pods, yurts, wigwams, and tepees.
These have been grouped together and covered in Policy statement TWR5.
Policy TWR5 does not differentiate between AONB areas and non-AONB areas.
There is therefore possible ambiguity between Policy TWR3 and TWR5.

Policy TWR3 needs to provide a definition of "permanent alternative camping accommodation" in a Citation similar to 1 and 2 on page 114.
Changes cannot be suggested without being provided with a definition.

Representation ID: 483

OBJECT Cadnant Planning (Mr Rhys Davies)

Summary:

The policy effectively places an embargo on additional static caravans within the AONB and SLA's. This provides no incentive to owners and operators to bring forward improvements to their sites. The effective embargo on additional caravans is contrary to National Planning Policy which places an increased emphasis on the economic benefits of tourism.

Representation ID: 458

SUPPORT Bourne Leisure Ltd represented by Nathaniel Lichfield & Partners (Mr Arwel Evans)

Summary:

Aspects of TWR3 are supported as it facilitates proposals to improve existing static and chalet sites provided they conform to a number of criteria.

Representation ID: 308

OBJECT Point Lynas Caravan Park/Pant y Saer Caravan Park (Mr Peter Hoyland)

Summary:

Item 3 iii of Policy TW3 is insufficiently flexible to achieve the policy aims. A small increase in the number of static caravan or chalet pitches on the park will be considered if it can be shown that they are a requirement for an improvement scheme to be viable.

Representation ID: 223

SUPPORT Lafarge Tarmac Trading Limited represented by Pleydell Smithyman Limited (Mr Robert Price)

Summary:

Recreation and tourism uses are viable end uses of previously used land at mineral extraction sites that when restored can provide facilities such as hotel opportunities, camping sites, woodland lodges and caravan parks where appropriate.

Representation ID: 222

SUPPORT Ellesmere Sand & Gravel Company Limited represented by Pleydell Smithyman Limited (Mr Robert Price)

Summary:

Recreation and tourism uses are viable end uses of previously used land at mineral extraction sites that when restored can provide facilities such as hotel opportunities, camping sites, woodland lodges and caravan parks where appropriate.

Representation ID: 197

OBJECT Kingsbridge Caravan Park (Mr Andrew Bate)

Summary:

Whilst I would agree with the proposal to refuse the development of NEW parks within the AONB, consideration should be given to the proposal to restrict the increase in numbers of units in AONB areas. This may lead to increased demand for second homes from visitors. The effects of this are evident in Rhosneigr and Trearddur Bay.

I would like to see a degree of flexibility with each case considered on its own merits and perhaps negotiation between planners and park owners.

Representation ID: 96

OBJECT BH&HPA represented by Savills (UK) Limited (Mr David Middleton)

Summary:

Policy TWR3 should adjudge planning applications for holiday caravan parks located within the AONB and SLA's against a common set of criteria which should apply to all parks. If a development proposals can demonstrate significant environmental improvements to the design, layout and appearance of a holiday park then they should be encouraged regardless of where they are located. If the overall impact of an existing site is reduced and/or significant economic benefits would result, then there is no sound reason to preclude against additional pitches. The incentive needs to be there to assist in funding these often expensive development projects.

Amended Policy

1. Delete Point 3
2. Amend Point 4 to allow proposals to improve existing static caravan and chalet sites by allowing minor extension to site area, and/or The relocation of units and/or, A minor increase in the number of units on site subject to detailed criteria. See full submission for detailed text.

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